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Under COPPA, how do I know if my channel is “directed to children”? Since the FTC and New York Attorney General announced their September 2019 settlement with YouTube for violations of the Children’s Online Privacy Protection Act Rule, we’ve heard that question from channel owners – sometimes called content creators. If you’re a channel owner who shares content on user-generated platforms like YouTube, read on for FTC staff guidance about the applicability of the COPPA Rule and how those covered by the Rule can comply with its requirements.

The FTC action against YouTube and Google

The lawsuit against YouTube and Google alleged that the companies illegally collected personal information from children, in violation of COPPA. According to the complaint, the companies collected that information from viewers of child-directed YouTube channels in the form of persistent identifiers that track users across the Internet, but didn’t notify parents and get their consent. To settle the case, YouTube and Google agreed to create a mechanism so that channel owners can designate when the videos they upload to YouTube are – to use the words of COPPA – “directed to children.” The purpose of this requirement is to make sure that both YouTube and channel owners are complying with the law.

A COPPA recap

That provision of the settlement has raised questions among content creators about how to determine if what they upload to YouTube or other platforms is “directed to children.” The answer requires a brief summary of some key COPPA provisions. Passed by Congress in 1998, the Children’s Online Privacy Protection Act is a federal law that protects the privacy of children under 13. COPPA’s foundational principle is one that most people can agree on: Parents – not kids, companies, platforms, or content creators – should be in control when it comes to information collected from children online.

The FTC enforces the law through the COPPA Rule. In general, COPPA requires operators of commercial websites and online services that are directed to children (more about that in a minute) to provide notice and obtain verifiable parental consent before they collect personal information from kids under 13.

The COPPA Rule defines “personal information” to include obvious things like a child’s first and last name or home address, but that’s not all. Under COPPA, personal information also covers what are called persistent identifiers – behind-the-scenes code that recognizes a user over time and across different sites or online services. That could be an IP address or a cookie when it’s used to serve targeted ads. Keep in mind that an operator also might be collecting personal information through an open comment field on its site or service that allows a user under 13 to make personal information publicly available. For example, think of a comment like this on a child-directed site: My name is Mary Jones from Springfield. I love this video!

How COPPA applies to channel owners

So how does COPPA apply to channel owners who upload their content to YouTube or another third-party platform? COPPA applies in the same way it would if the channel owner had its own website or app. If a channel owner uploads content to a platform like YouTube, the channel might meet the definition of a “website or online service” covered by COPPA, depending on the nature of the content and the information collected. If the content is directed to children and if the channel owner, or someone on its behalf (for example, an ad network), collects personal information from viewers of that content (for example, through a persistent identifier that tracks a user to serve interest-based ads), the channel is covered by COPPA. Once COPPA applies, the operator must provide notice, obtain verifiable parental consent, and meet COPPA’s other requirements. For information on how to comply with COPPA, please visit the FTC’s COPPA page for our Six-Step Compliance Plan for Your Business.

How channel owners can determine if their content is directed to children

Under COPPA, there is no one-size-fits-all answer about what makes a site directed to children, but we can offer some guidance. To be clear, your content isn’t considered “directed to children” just because some children may see it. However, if your intended audience is kids under 13, you’re covered by COPPA and have to honor the Rule’s requirements.

The Rule sets out additional factors the FTC will consider in determining whether your content is child-directed:

  • the subject matter,
  • visual content,
  • the use of animated characters or child-oriented activities and incentives,
  • the kind of music or other audio content,
  • the age of models,
  • the presence of child celebrities or celebrities who appeal to children,
  • language or other characteristics of the site,
  • whether advertising that promotes or appears on the site is directed to children, and
  • competent and reliable empirical evidence about the age of the audience.

The determination of whether content is child-directed will be clearer in some contexts than in others, but we can share some general rules of thumb. First, unless you’re affirmatively targeting kids, there are many subject matter categories where you don’t have to worry about COPPA. For example, if your videos are about traditionally adult activities like employment, finances, politics, home ownership, home improvement, or travel, you’re probably not covered unless your content is geared toward kids. The same would be true for videos aimed at high school or college students. On the other hand, if your content includes traditional children’s pastimes or activities, it may be child-directed. For example, the FTC recently determined that an online dress-up game was child-directed.

Second, just because your video has bright colors or animated characters doesn’t mean you’re automatically covered by COPPA. While many animated shows are directed to kids, the FTC recognizes there can be animated programming that appeals to everyone.

Third, the complaint in the YouTube case offers some examples of channels the FTC considered to be directed to children. For example, many content creators explicitly stated in the “About” section of their YouTube channel that their intended audience was children under 13. Other channels made similar statements in communications with YouTube. In addition, many of the channels featured popular animated children’s programs or showed kids playing with toys or participating in other child-oriented activities. Some of the channel owners also enabled settings that made their content appear when users searched for the names of popular toys or animated characters. Want to see the FTC’s analysis in context? Read pages 10-14 of the YouTube complaint.

Finally, if you’ve applied the factors listed in the COPPA Rule and still wonder if your content is “directed to children,” it might help to consider how others view your content and content similar to yours. Has your channel been reviewed on sites that evaluate content for kids? Is your channel – or channels like yours – mentioned in blogs for parents of young children or in media articles about child-directed content? Have you surveyed your users or is there other empirical evidence about the age of your audience?

What are the possible penalties for violating COPPA?

The Rule allows for civil penalties of up to $42,530 per violation, but the FTC considers a number of factors in determining the appropriate amount, including a company’s financial condition and the impact a penalty could have on its ability to stay in business. While Google and YouTube paid $170 million, in another COPPA case settled this year, the operator paid a total civil penalty of $35,000.

Isn’t the FTC taking another look at the COPPA Rule?

Yes, the FTC is currently evaluating the Rule in light of rapid changes in technology. If you would like to comment on the effectiveness of the COPPA Rule and whether changes are needed, the FTC has extended the comment deadline to December 9, 2019.

Where can channel owners go for more information?

A look at the factors in the COPPA Rule will help most channel owners determine if their content is directed to children. If you’re still unsure about how COPPA applies to you, consider contacting an attorney or consulting with one of the COPPA Safe Harbor programs – self-regulatory groups that offer guidance on how operators can comply with the law. Visit the FTC’s website for a list of currently approved Safe Harbor organizations. For more resources, visit the FTC’s Children’s Privacy page for our Six-Step Compliance Plan for Your Business.

 
 
 

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Guest
December 08, 2019
It would be better if instead of categorizing kids, and adults, they just put a filter so "kids" can't share private information. They have systems like this on lots of popular games with chat. It would be much less a hassle of categorizing everything. What about if we want to share our content with "kids" and "teens"? Yes having a mixed option would be good, but why have to filter out content in the first place. Filtering the comments so kids can't share information would be much more simpler. -It would be nice if COPPA or youtube would consider this.
David
December 08, 2019
I understand the concern of parents and the FTC. However, I feel there are some problems regarding the implementation of COPPA on content creators. For one thing, the guidelines for what constitutes content that is "directed to children". I personally feel it is unfair for content creators to be punished for the actions of user-generated platforms. If COPPA goes into effect, it will become the responsibility of content creators for the actions of the individuals who are in charge of the platform. I encourage the FTC to reconsider COPPA. If any action must be taken to enforce these guidelines, I feel the consequences should fall to the those in charge of the platform and not those who make content for the platform and have no say over what the platform does. Thank you for taking the time to read this comment.
???
December 08, 2019
Why even have a mixed content? We don't need to "age" filter at all...Instead why not just filter comments.There are plenty of games, and sites, that use filter chat so that "kids" can't share private information online. YouTube could have looked into this also. -It would be nice if YouTube would look into this- It would be much simpler for viewers, and creators.We shouldn't be mad at creators of kids. It's not there fault (older kids should know better though). YouTube should have thought of this in the first place.
Marc-André Pilote
December 08, 2019
There is one thing I do not understand. Does the $ 42,530 kernel happen if we use children illegally for our videos, or whenever our videos are misclassified? if I say that my video is not for kids, but YouTube thinks otherwise, am I paying $ 42530 for the almond, or not?
Guest
December 09, 2019
I have an interesting question: If you point out in the video (i.e. In the title, beginning and ends of the video, and in the description) that your content is for an audience of 13 or over, does that comply with COPPA? The reason why I am asking this is because if the creator puts an age warning stating that the video is meant for older audiences, then that should mean the creator pointed out their target audience, though, I might've missed something while researching.
Cristy H
December 09, 2019
Regulations are not going to stop kids from lying about their age to access content or use online services. Though your regulations state protection of children as your goal, the unintended consequences, the cumulative effect of YouTube having lost major advertisers due harmful videos and the way YouTube is using this law as an excuse to discourage any content creators from making videos for children by removing any incentives to create and removing ability for children to find or follow the creators. My children absolutely love a Minecraft YouTuber and use the platform for various educational and nature videos. I love to watch tutorials and tips on watercolor painting. I also learned how to change the cabin air filter in my car and various other helpful videos. I don’t think what the FTC is proposing with COPPA I has I’ll intentions. It isnYouTube’s undermining approach, using COPPA an excuse, to win back lost advertisers. However, I do believe government restrictions are overreaching the bounds, parents have the rights and responsibilities to restrict or allow their children’s actions.
Andre kampf
December 09, 2019
What about gaming channels that play games that might appeal to kids like fortnite or pokemon. These games could be considered kids games but adults play them too and we can't control who watches our videos. What if you play these games but your content not made for kids . Would you consider it for kids content the rules are to vague and make it open to interpretation which is a problem for creators trying to comply with them.
Guest
December 09, 2019
There is a significant and obvious flaw in the mentality behind this law, and that is in the creation of "kid's content" as an absolute and distinct form of criteria. COPPA is United States law, but it applies globally to all communities across every culture. What applies as "kid directed content" in one society is different to what is even considered appropriate for adults in another. Even within different subsets of a nation's population, different people are going to decide what is "for kids" in different ways. In addition, over the course of time, these standards will inevitably change within the context of every society. This law sets out to create an utterly vague and culturally tone-deaf definition of what "kid's content" is defined to be. The problem is that it is entirely subjective as to what constitutes "kid's content". It's an opinion, more than fact, whether set of identifiers REALLY counts as "kid's content". US law presumes to define one standard that all societies across the world are to be legally bound to? Is that even Constitutionally sound? This seems like it could potentially cross into the territory of a violation of free speech/expression. This is a matter that has potentially disastrous legal consequences on certain content creators who exist somewhere between the general audience exception and "kid's content", so you NEED to outline an absolutely exact set of criteria as to what qualifies as, beyond ANY form of ambiguity, "kid's content". But how can that possibly be done fairly on a global level and context when the definitions of what counts as "kid's content" differs between cultures and generations? And these standards/outlines have to somehow be applicable within every society and culture, and be amended in light of changes throughout generations, which is exceedingly unlikely to happen. The current outlines are unacceptably vague, and because of this, it is almost guaranteed that many innocent content creators will face penalties where it is not remotely warranted. Why not instead focus on the real problem in this situation; the gathering of personal data? Personal data should not be obtained through YouTube, Google, Facebook or any other website in any way, regardless of the age of the user. ANYONE can become a victim through the misuse/misappropriation of their online information. Security measures should be put in place that make the misuse of people's personal information far less likely to occur. Then, it wouldn't matter whether kids lie about their age to create a YouTube account. They won't become victims if YouTube (or other entities) are unable to SHARE that personal information. Another thought: what if you delete your entire channel in an attempt to avoid violating the law? Let's say a certain video on your channel wound up being viewed mostly by kids. Personalized ads were present and the kid's personal data was involved. Are you now guilty of violating COPPA? Can YouTube or FTC go through the records of how and where kids' information was gathered and find your video(s)/channel to be guilty, even if you had no possible way to know? Then what?
Guest
December 09, 2019
what about Kids actors in horror movie on youtube?
Guest
December 09, 2019
Yes
Guest
December 09, 2019
I understand this COPPA thing now but I’m still unsure about inappropriate language (swearing).
LeviathanYT1
December 10, 2019

In reply to by Guest

More than likely swearing will fall under language kids won't understand
Guest
December 09, 2019
Nooo!!! We don't Need this!
Guest
December 09, 2019
As a Christian, I don't do a lot of mature content, but my Channel is not directed at kids. I handle or talk about subjects kids should not hear. I review PG-13 movies or mature games. I shouldn't be punished because my content is clean. I make it for people my age (in their 20s). Its a community for my Christian friends to come and watch content made for them. Other people are welcomed cause I make it for all. There isn't a lot of content for Christians out there that don't go overboard on the mature content so, I try to provide something we can watch. Thank You.
Guest
December 09, 2019
Can you please reconsider for people on YouTube that make content for all ages on the site because this might do more harm then good.
lillysYT
December 09, 2019
Please stop coppa for YouTube. You didn't need to sue yt because parents tell their kids if they are able to use YT. Just please reply to me, I'm scared we all are gonna get sued because my family is poor and I dont wanna get sued... please...
Guest
December 09, 2019
Excuse me FTC, but please do not put the blame on creators. This is all YouTube's fault, YouTube violated COPPA, not creators. Most creators make content for general audiences, so please threaten YouTube into allowing creators to label their content as such! COPPA poses a threat to people's livelihoods!
Ida
December 09, 2019
Any sort of fine would simply ruin me! I am experiencing growth on my ASMR Channel and would hate to stop uploading in fear of boing bankrupt. Please make your guidelines CLEAR because we simply cannot tell whether our content is child friendly or not.
Tom Kvichak
December 09, 2019
Being a content creator on YouTube I have no control of anything but the content I produce. Even though I choose to monetize my content, I have no control of or am not responsible for any aspect that the FTC has jurisdiction of such as Web owner or social media platform. I have no control over, where my video is placed, how many people it is displayed in front of, or how many or what ads are placed next to my content, or what cookies are placed on the viewers device. I am also not able to inform any parent of the content or cookies collected or placed. Content creators can not collect any data from their videos other than the limited amount of data the service provider allows it's users to see. Content creators are users of a service, not owners of the service. We may use the channel name on YouTube and that is all we have control of on YouTube except the content we upload to the service. The social media platform has complete control of everything that happens to my video after I upload it to the service. The only thing I control as a content creator is the content I produce. In my opinion, my content is definitely not for kids but who's to say, other than one of your employees, what is child directed or not child directed. The rules for this determination are so vague, that it is nearly impossible to determine what is child directed unless it is obvious to all viewers that the content is for children. The more you try to regulate what children are exposed to will result in more content not suitable for the children to watch. They will find a way because the parents that are responsible for what these children are exposed to are not protecting their own children. Like the closing statement from the good doctor in your work group stated. "The parents have enough to worry about, they don't need the extra pressure of policing their children." If the parents don't take the time to police their own children, then THEY are failing their children, not anyone else. You can't continue to regulate outsiders if the parents don't take the first step, or any step to regulate what the children are exposed to everyday! I ask that you consider the following: 1. Establish better definitions of child directed content. 2. Place parents back into being responsible for what their children watch. 3. Keep web operators & social media platforms responsible, not their customers (content creators). 4. Establish fines for parents who neglect the safety of their children by allowing them access on non protected devices.
tjhnson
December 09, 2019
I"m all for protecting children, but there seems to be more gray area than not for so many "family friendly/clean" youtube videos/channels that are not directed towards children but with the current wording if one child decided they were interested in the content, the channel owner would be liable for fines although they had no intention of marketing their videos to children, and no control over how youtube collects data but simply because their content is clean and not offensive, could be considered of interest to some child at some time.... It seems like it would be more practical to put the responsibility on Youtube or any other provider to have the viewer verify their age is over 13 (or whatever the critical age is) and how they collect data (what type of data) from those viewers... without exposing perfectly harmless DIY Craft videos, and similar type channels that have G rated content but do not intend to have an audience of children's to fines and penalties or have the only other option be to have all their comments & interaction removed, and their chance for monetization on their channels greatly minimized to the point they just won't produce any content for fear of retribution by the FTC...
concerned view…
December 09, 2019
The new rule is unproductive because... It's unjust: creators should not be penalized for parents' poor decisions. There's already a YouTube Kids. If the parents do not utilize it, the responsibility should be on them. It's too harsh: creators can be fined for accidentally mislabeling a video. It kills channels: child-appropriate channels (even if they're adult-targeted) may shut down to avoid fines or be de-monetized and die for lack of income. It's too vague: there is no clear definition for what makes a kids video, increasing the likelihood for honest mistakes. It's ironic: because child-appropriate channels will shut down or go bankrupt, the rule meant to protect kids will decrease the amount of child-appropriate media available on the internet. In short, it's a mistake.
Guest
December 09, 2019
what about animations for adults?
Mike
December 09, 2019
So how does COPPA apply to channel owners who upload their content to YouTube or another third-party platform? COPPA applies in the same way it would if the channel owner had its own website or app. Dear FTC, how can this be the case please? We as channel owners have no access to viewer data collected by Youtube or Google. We have no control over YouTube or Google. We do not ask for this data or require it. We have no way at all to ask parents for permission. All we do is upload a video to YouTube, after that other than removing the video we have no control how it is served by YouTube. I hope you can accept this and change things accordingly?
Guest
December 09, 2019
If I ask a question, can I please get a response? If someone has a private YouTube channel just for "family videos", how is it to be marked? For kids...since the videos are of the kids? Even if nobody is going to see them except family members and a few close friends, how should it be marked?Thanks!
LeviathanYT1
December 10, 2019

In reply to by Guest

From what i know al private videos will be an exception
Jane
December 09, 2019
Its interesting that the "creators" are commenting , but not offering any solutions to the issue. The facts are that these "creators" are the first in line to define who their videos target. I don't see any proactive going on in the vlogger community to address the privacy of kids. Its about time that the FTC gets involved and has to establish safe ways to prevent "creators from targeting children.
Joshua
December 10, 2019

In reply to by Jane

The only thing a youtuber can see, if not blocked on the youtubers end is usernames. It's not a youtubers fault if their underage viewers post their first and last name along with their comments. It's their parents fault for not teaching them. The FTC is not the ones to be a parent. And youtube is not a babysitter. It's called raising your kids correctly to not be dumb online!
Why would I pu…
December 14, 2019

In reply to by Jane

It states in the youtube terms of service that kids under 13 should not be watching youtube. The youtube kids app is there for that. Us creators cannot control children who live thousands of miles away who decide to lie about their age. The FTC needs to realise that youtube isn't just a hobby, it is some people's jobs. One solution, enfore the terms of service, tell parents to control their children online. Creators are not responsible for a random child.
ajgodinho
December 09, 2019
First of all, I'm all for protecting kids. And I'm all for protecting privacy, not only for kids, but for everyone. I've spent a lot of time reading and trying to understand how all this transpired with COPPA, the FTC and YouTube/Google. My take on this is simple. YouTube is meant for people 13 and over (as per their Terms of Service). I understand that YouTube/Google were at fault (and for good reason) with them approaching advertisers to target kids under 13 in terms of collecting data from videos that kids watched. The big issue here is that YouTube creators are being penalized for no fault of ours. We are content creators and I personally don't create content specifically directed towards kids. Even if I do create review or tutorials on certain toys, programs or services, they are directed towards parents. I was looking at my YouTube analytics and my lifetime audience is mostly between 18 and 54. With these COPPA changes, I'm really finding it hard to actually determine which videos may be deemed "child-directed". Why? Because I create review and tutorials which are for adults, but when I take a closer look, I'm questioning myself (without a clear cut understanding) if any of my videos may be deemed "child-directed". If I want to be on the safer side, I would have to mark many of my videos as "made for kids" when in fact, none of them are made for kids. They are for a general audience. In fact, I could argue that my content is certainly directed towards adults, including parents. If I mark many of my videos "made for kids", I'm going to lose a lot in terms of features like the comments section and of course, the bigger issue would be a huge loss in earnings. I rely on the comments section to engage with my audience and because it has to do with reviews and tutorials, the comments section is essential because my audience has questions and this is a way for me to help them. I rely on my YouTube earnings as I've had to leave my corporate job because of a medical condition and have to work from home. This has not only been therapeutic to me, but also have been a way for me to earn an income while working hard doing what I love to do. By unfairly imposing these new COPPA rules on us content creators, this has caused me a lot of stress. I'm a small creator and can't afford to higher lawyers to guide me through this. If I mark my videos "made for kids" (to be on the safer side) when they are really not for kids, I would be penalized. And if I don't mark them "made for kids", I could be putting myself in a position where the FTC fines me big time which will pretty much be the end of me. You have provided an update on the COPPA rules, but these are just guidelines that don't really help much. We would still need to consult a lawyer to be a 100% sure. This would pretty much result in me completely giving up on YouTube with no recourse. Think about how you are negatively impacting so many content creators on YouTube for no fault of ours. You have done your job and fined YouTube/Google for their mistakes. I'm sure they will be more careful in terms of how they use the data. But, the crux of the matter is really that kids under 13 should not be on YouTube, they should be on YouTube Kids. We should not have to mark our videos as "made for kids" on the general YouTube site because most of us create videos for adults which may be deemed for kids (as per the new COPPA rules) and this is absolutely unfair that you're penalizing us creators. Yes, YouTube/Google made a mistake, but you've already fined them and I'm hoping they've learned their lesson. They have promised to be responsible going forward, so I would urge you to rethink these new COPPA rules and especially how they negatively impact us content creators. Thank you for your consideration!
User_8527
December 14, 2019

In reply to by ajgodinho

Amen. I agree. I also live off my youtube earnings. Similar situation. I upload gaming videos, minecraft. roblox, poly bridge, cities skylines, etc. My content is directed to people ages 13-18 I would say. Not for kids, but also not for adults.
Chris
December 14, 2019

In reply to by ajgodinho

I totally agree with you. I doubt people like you commented to, really has a solution themselves. Half of anybody doesn't realizes people are doing YouTube and rely on it for their primary income and that its their livelihood like you do. To be honest if it wasn't for YouTube I would of never learned how to do certain things. I would of never got anything done that was important to me. I'm seriously appalled they would consider doing this and holding the content creator responsible, which is insidious. Since this is this case, why don't offer an option for mixed audience or video contains content both audiences for children under 13 and older (over 18) That way nobody is going to have to deal with astronomical fines and losing their channel.
Guest
December 09, 2019
So I feel like my content will be aimed at 13+... as it contains blood and death.... even if my content has bright colors it’s becuase of the style of the game I’m fan making (Daganronpa) whould that men I need to set my tabs to safe for kids or not safe for kids...
Guest
December 09, 2019
YouTube Kids? Does that not exist to you or...
Anon
December 09, 2019
Is the COPPA rule directed toward youtubers who create content like Ace family, Or Royalty Family? I feel that these are aimed to younger children and should be affected by this rule.
I Honey •Leaf•…
December 09, 2019
Hello FTC, I understand that COPPA is to keep children safe but some YouTubers will be affected by this & some YouTubers need YouTube to earn money. Like me but I don't have enough Subscribe to do so. But Please don't make the fine $42,000 b/c ( because ) some YouTubers don't have enough money. Have a great day - Honey •Leaf•
Anita M.
December 09, 2019
Does this also affect channels that are not monetized yet?
Hal
December 09, 2019
I understand wanting to protect the children based on what they watch on YouTube, but hitting content creators with stiff fear monger induced fines isn't the proper way. and with how the guidelines are, content creators are going to turn to only making content towards adults, since they will be who can view their content and pull in revenue for Creators to survive. Unfortunately, This will cause content YouTube to no longer be a place for kids to view media, including media that might target a mixed audience. Gamers specifically. Many popular content creators are gamers and with content of this nature having a mixed audience, a creator may end up getting fined over this, even with channel vids set to "Not target kids" YouTube may end up being adult only with the way these legal guidelines/enforcements are, and with many popular content creators looking at their channels and seeing what can get them into hot water, they may end up changing things to content with Mature or R-rated media, which will cause indirect exposure to kid who pick up, or are given their parent's mobile devices to watch YouTube on their screen names. And since YouTube can't tell if a user is watching Call of Duty vids, or if said user's child is watching it, this will make YouTube more degenerate to younger audiences. I guess, once all of this goes into effect, YouTube will no longer be a place for young audiences to watch videos come 2020.
Eris
December 09, 2019
Simple fact: content creators do not have access to the information gathered by advertisers, marketers, YouTube and its parent company Google.. Those collecting information on children under 13 should be fined! When I had a blog, it wasn’t monetised yet adverts were still placed on my blog without my consent. I had ZERO access to the information advertisers collected. That is no different even though a YouTube channel chooses to monetise. They still have ZERO access to information collected, Placing such a large fine on a content creator can destroy a family; the very thing COPPA seeks to protect. How does that help children if they’re homeless? Furthermore there are many crossover subjects. E.g., adults who run animal rescue or sanctuaries, anyone with a pet who might wander into a video, gamers, artists, every adult who likes cartoons, bright colours, collects toys, and the common usage of all ages of slang. If I’ve read this correctly, even if you’ve marked your channel as an “adult audience” but used any of the aforementioned (and more) each video can be fined, correct? I’ve been collecting and often selling parts or all of my collections of vintage/antique items that would appeal to children such as dolls, lunchboxes. If I wanted to start a channel teaching about these items under COPPA I’d be hit with fines, even if marked as an adult audience and I have ZERO access to information gathered if monetised, correct? If this is indeed correct, there’s another family that will be homeless. PLEASE take into consideration who LITERALLY collects information on children! I believe I read there was another “mixed” audience” option you put forth, but YouTube and Google are ignoring this as they feel they need to pass the blame on others since they were fined. Can this not be legally instated to help rather than destroy content creators who aren’t to blame?
Guest
December 09, 2019
Dear, Federal Trade Commission You should not credit creators on children's watch history for all kids will have to do is use google to up there age I did it when I was a kid I am just saying that you should not define what is or is not for kids since most creators want it to be towards everybody and if you do this then MILLIONS of people are out of jobs because of this one rule but is not two late to fix this mistake I am just asking from the bottom of my heart please don't ruin YouTube it It is a platform to where creators make it their job to entertain if you take YouTube away then your taking away entertainment from the people and you do not want to be known for doing that I write this in the respect of everyone please take down for kids. -sincerely James Ermerson
ceb1031
December 09, 2019
YouTube is not going to deal with COPPA!
D'Squarius Green Jr
December 09, 2019
The new application of the COPPA law will do nothing but hurt content creators and children. The only thing it really accomplishes is shifting liability from Google/Youtube to the individuals who post videos on the site. By forcing people to declare their videos as "made for kids" or not, creators will face the choice of losing 90% of their income, or potentially being hit with a $42,000 fine. The FTC needs to be aware that thousands of people make a living creating content on Youtube and that COPPA could potentially destroy their livelihood. As it pertains to children, this application of COPPA really does very little to protect their privacy. It's pretty naive to assume that children will only be watching content that is "made for kids". Any time a child watches a video aimed at adults, their data will still be collected. It also appears that there is no way to distinguish when an adult is watching a video made for children. In addition, there will almost certainly be a decline in child friendly content due to the fact that creators will now be penalized for creating it. When it comes to protecting children online, the responsibility should fall on the parents rather than the federal government. When a parent allows their children to use devices that can access Youtube or any other site, it should be viewed as parental consent that cookies and other data may be collected. Then we can all get back to business as usual.
Willowfrost31
December 09, 2019
In order to make a YouTube account you must be at least 13 plus, so technically if kids are being tracked its because they told YouTube they were teens. Theres also a YouTube kids app for those under 13 which, as far as I'm aware, does not track information.
Jay
December 10, 2019
Holding creators of content responsible for the actions of the company that owns the platform places the creators in an impossible situation that can not possibly be resolved no matter what advice is given in a list or saying that they should contact their lawyer. This is a complete shut down of creators and there is no way to pretend it is anything else. The federal governments claims to want to protect children's information yet reduces their need for supplemental nutrition assistance by a reduction in SNAP benefits. How many children would right now lack any health care if not for John McCain? The risk for creators is now infinite and we are done because of this.
Guest
December 10, 2019
Music only
Guest
December 10, 2019
Your law is so vague but threatening. What about Kids Broadcasters that have no interaction nor collect any data or personal information from children? There are behind the scenes stats on viewers like IP addresses etc. Adding this as "collecting personal information" basically puts all Kids Broadcasters at risk of a hefty fine. Is the FTC collecting the IP address of anyone commenting here? If so, how do you know it is not a kid? If so, aren't you violating the same law you have created?
FTC Staff
December 10, 2019

In reply to by Guest

The Privacy Act Statement, directly above the box where you added your comment, explains that it is your choice whether to submit a comment. If you do, you must create a user name, or we will not post your comment. The Federal Trade Commission Act authorizes this information collection for purposes of managing online comments. Comments and user names are part of the Federal Trade Commission’s (FTC) public records system (PDF), and user names also are part of the FTC’s computer user records system (PDF). We may routinely use these records as described in the FTC’s Privacy Act system notices. For more information on how the FTC handles information that we collect, please read our privacy policy.

Miraj
December 10, 2019
Nice
Guest
December 10, 2019
Will channels that aren’t monetized be affected? What about gacha videos that are for older audiences?

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